ON-SITE WASTE DISPOSAL FACILITY (OSWDF) PROJECT QUALITY ASSURANCE PLAN PIKETON, OHIO

Transcription

1 Fluor-BWXT Portsmouth LLC ON-SITE WASTE DISPOSAL FACILITY (OSWDF) PROJECT QUALITY ASSURANCE PLAN PIKETON, OHIO Fluor-BWXT Portsmouth LLC Date Issued June 7, 2017 Prepared by Fluor-BWXT Portsmouth LLC Managing Environmental Management Activities at the Portsmouth Gaseous Diffusion Plant Under contract DE-AC30-10CC40017 for the U. S. Department of Energy Portsmouth Gaseous Diffusion Plant Piketon, Ohio 1 Year Periodic Review Date: 05/30/18 This document contains 43 pages.

2 APPROVALS FBP-ER-PL Fluor-BWXT Portsmouth LLC ON-SITE WASTE DISPOSAL FACILITY (OSWDF) PROJECT QUALITY ASSURANCE PLAN June 7, 2017 Approval Approval Approval Frank Miller (Signature on File) Frank Miller, OSWDF Project Director Portsmouth GDP D&D Project Fluor-BWXT Portsmouth LLC Steven Guthrie (Signature on File) Steve Guthrie, OSWDF Deputy Director Portsmouth GDP D&D Project Fluor-BWXT Portsmouth LLC Darryl Howe (Signature on File) Darryl Howe, OSWDF Project QA Manager Portsmouth GDP D&D Project Fluor-BWXT Portsmouth LLC 05/30/17 Date 05/30/17 Date 05/30/17 Date REVISION LOG Revision Number Revision Date Description of Changes Pages Affected 0 09/15/16 Initial Issue All 1 05/30/17 Minor Revision/Periodic Review to update template, logos, titles, and references All ii

3 TABLE OF CONTENTS 1.0 OSWDF PROJECT PROJECT DEFINITION ORGANIZATION AND RESPONSIBILITIES PROJECT QA RESPONSIBILITIES STOP WORK AUTHORITY MANAGEMENT PROCESSES GRADED APPROACH PERSONNEL TRAINING AND QUALIFICATION QUALIFICATION AND TRAINING OF PERSONNEL QUALIFICATION OF INSPECTION AND TEST PERSONNEL QUALITY IMPROVEMENT QUALITY IMPROVEMENT PROCESS NONCONFORMING ITEMS DOCUMENTS AND RECORDS DOCUMENTS RECORDS WORK PROCESSES INSTRUCTIONS, PROCEDURES, AND DRAWINGS IDENTIFICATION AND CONTROL OF ITEMS CONTROL OF SPECIAL PROCESSES CONTROL OF MEASURING AND TEST EQUIPMENT HANDLING, STORAGE, AND SHIPPING INSPECTION, TEST, AND OPERATING STATUS DESIGN CONTROL BASIC DESIGN INPUT DESIGN PROCESS DESIGN ANALYSIS DESIGN VERIFICATION CHANGE CONTROL INTERFACE CONTROL CONTROL OF ENGINEERING SOFTWARE PROCUREMENT PROCUREMENT DOCUMENT CONTROL CONTROL OF PURCHASED ITEMS AND SERVICES CONTROL OF SUPPLIER GENERATED DOCUMENTS ACCEPTANCE OF ITEM OR SERVICE CONTRACTOR PERFORMANCE CONTROL OF SUPPLIER NON-CONFORMANCES COMMERCIAL GRADE ITEMS (CGI) INSPECTION AND ACCEPTANCE TESTING INSPECTION TEST CONTROL AND M&TE iv

4 9.0 ASSESSMENTS SUSPECT/COUNTERFEIT ITEM (S/CI) S/CI SOFTWARE QA (SQA) SQA DEFINITIONS/ACROYNS DEFINITIONS ACRONYMS REFERENCES iv

5 INTRODUCTION FBP-ER-PL This Project Quality Assurance Plan (PQAP) provides the primary requirements for the integration of quality functions during the design, construction, and operational phases of the On-Site Waste Disposal Facility (OSWDF) located in Piketon, Ohio, for the U.S. Department of Energy (DOE) Portsmouth Paducah Project Office (PPPO), under prime contract DE-AC30-10CC This PQAP was written to meet the contractor quality assurance (QA) requirements of DOE Order (O) 413.3B, Program and Project Manage for Acquisition of Capital Assets, which requires the development and implementation of a Quality Assurance (QA) program in accordance with DOE O 414.1D, Quality Assurance; Title 10 Code of Federal Regulations (CFR) Part 830 Subpart A, Quality Assurance Requirements; and American Society of Mechanical Engineers (ASME) Nuclear Quality Assurance (NQA-1), Quality Assurance Requirements for Nuclear Facility Applications (2008 edition, with addenda through 2009), DOE Office of Environmental Management (EM) Quality Assurance Program (QAP), EM -QA-001. This PQAP incorporates the requirement of Fluor-BWXT Portsmouth LLC (FBP) FBP-QA-PDD-00001, Revision 7, Quality Assurance Program Description (QAPD), which allows the development of additional quality assurance plans to provide supplemental project specific guidance. This document is a flow-down of quality requirements from the QAPD. If a specific requirement is not clearly stated in this PQAP, refer to the FBP QAPD for further guidance. If a conflict arises between this PQAP and the FBP QAPD, the requirements of the FBP QAPD will take precedence. FBP policies, plans, and procedures used to implement the requirements of this document are referenced in the applicable sections of this PQAP. The requirements within the FBP-PM-PDD-00001, FBP Integrated Safety Management System (ISMS), will be implemented on the project. This PQAP will be reviewed annually and revised as necessary, to incorporate changes in QA requirements, project scope, or entering a new phase of the project relative to design, construction, waste placement, or operations. v

6 1.0 OSWDF PROJECT FBP-ER-PL PROJECT DEFINITION This PQAP is developed to flow down requirements from the FBP QAPD and is a quality management system consisting of three elements: managing, performing, and assessing the quality and adequacy of work performed within the scope of the OSWDF project The management element includes programs that establish organizational structures and responsibilities, as well as management processes including planning, scheduling, and resource considerations. This element also includes personnel training and qualifications, quality improvement, and management of documents and records The performance element includes work processes, design activities, procurement, and inspection and acceptance testing required to plan and perform work in a manner that meets the scope and requirements of the OSWDF Project The assessment element includes independent and management assessments, surveillances, and inspections This PQAP flows down the managing, performing, and assessing the quality and adequacy of work elements, during the design, construction, and operation of the OSWDF. Future revisions will include the receipt and placement of impacted materials in the OSWDF and construction and operation of the Interim Leachate Treatment System (ILTS) The OSWDF will be designed and constructed using site controlled procedures, certified-forconstruction design documents and technical specifications; and operated in accordance with approved operating plans and procedures. All OSWDF work activities will comply with the FBP QAPD, OSWDF PQAP, and applicable QA requirements mandated by law and contractual requirements Environmental sampling and analysis will be performed in accordance the requirements in FBP-ER-PRO-WD-PL-0006, Sample Analysis Data Quality Assurance Project Plan (Sadq) At The Portsmouth Gaseous Diffusion Plant, Piketon, Ohio. The SADQ was developed to satisfy 1

7 sampling and data quality requirements for decontamination and decommissioning (D&D) under The April 13, 2010 Director s Final Findings and Orders for Removal Action and Remedial Investigation and Feasibility Study and Remedial Design and Remedial Action, including the July 16, 2012 Modification thereto (referred to as the D&D DFF&O)(Ohio Environmental Protection Agency [Ohio EPA] 2012), and for environmental cleanup under the Ohio Consent Decree and U.S. Environmental Protection Agency (EPA) Administrative Consent Order FBP OSWDF Project Management may delegate to others, such as contractors, agents, or consultants the work of establishing or executing the requirements of this PQAP, or any part thereof, but the OSWDF Project Management shall retain responsibility for all work activities governed by this PQAP Throughout the design, construction, and operations of the OSWDF; many organizations both FBP and subcontracted will be involved with execution of work activities. The responsibilities, interfaces, lines of communication, and authority of each organization shall be clearly defined through plans, procedures, and contract documents This PQAP shall be reviewed annually and revised as required to maintain compliance with regulations, DOE Orders and Directives, and any contractual requirements directing such change. The OSWDF Project Director shall be ultimately responsible for ensuring the annual review. The OSWDF Project QA Manager shall facilitate the review and approval of the OSWDF PQAP The requirements of this PQAP apply to all OSWDF project personnel and its subcontractors. 1.2 ORGANIZATION AND RESPONSIBILITIES OSWDF PROJECT ORGANIZATION AND KEY PERSONNEL ROLES & RESPONSIBILITIES The OSWDF Project organization is shown in Figure 1 with the OSWDF Project Director having overall responsibility for execution of the project. The OSWDF project is executed through the appointment of a project management team supported by personnel matrixed from FBP program support organizations, including but not limited to; Business Services; 2

8 Construction; Engineering; Environmental, Safety & Health, and Quality (ESH&Q); Operations; Project Controls; and subcontractors. This section will define the key roles and responsibilities for those who will have day to day responsibilities during the design, construction, and operation of the OSWDF. Not all roles and responsibilities identified in individual Roles, Responsibilities, Authorities, and Accountability (R2A2) are included in this document. A complete list of R2A2 s for a particular position can be found in individual R2A2 s. Responsibilities for those not included in this section will be defined in other OSWDF related plans, procedures, or work documents OSWDF PROJECT DIRECTOR Has overall administrative responsibility for the successful completion of the OSWDF through cost effective integration of construction, engineering, management, ESH&Q. Key project responsibilities include the following: Staff and organize FBP OSWDF Division. Requests and integrate matrixed resources from other functional areas into OSWDF organization. Recruits, qualifies, and assigns subordinate OSWDF managers and administrative. Administers compensation, performance management, and personnel development program for assigned staff (institutional and matrixed personnel). Ensures development & execution of training and qualification programs for OSWDF personnel. Prepare, execute, and conform to OSWDF Control Account budgets. Implements the DFF&O and Consent Decree requirements relevant to OSWDF work scope to support D&D. Is Overall responsibility for quality and safety on the project, and implementation of this PQAP. 3

9 1.2.3 OSWDF CONSTRUCTION MANAGER FBP-ER-PL Has overall responsibility for construction of the OSWDF. Key project responsibilities include: Ensure all work on the project is performed safely - activities are planned and performed in compliance with Integrated Safety Management System (ISMS) principles and core functions. Provides direction to Project Managers of capital asset projects. Ensures execution consistency between capital asset projects. Plays an active role in the development of the safety culture on the project. Remains knowledgeable of safety policies and procedures and performs assigns duties in a safe manner and, while supervising others, has responsibility for their safety; and ensures that they comply with established safety policies and procedures and practice safe work habits. Provides leadership and motivation to the project and organizational team as well as subcontractors and subordinate personnel. Follows Conduct of Operations requirements, prime contract terms, and company policies and procedures OSWDF DESIGN ENGINEERING MANAGER Is responsible for providing engineering design support to the OSWDF project. Key project responsibilities include: Planning, developing, and analyzing the design of the OSWDF. Performs and checks most types of civil engineering calculations and design using both computer-aided and manual design techniques on environmental remediation projects. Develops and prepares various technical documents, including proposals, specifications, work plans, technical evaluations, alternate analysis, and technical reports. Organizes, and plans work activities, develops and monitors estimates, assigns work, works with project team, client, field, and other organizations working on the project. Prepares estimates, scope of work, material, and service requisitions. Provides technical input during implementation of engineering studies, dampling and analysis plans, and other construction activities. Ensure that OSWDF design engineers are adequately trained and qualified OSWDF FIELD ENGINEERING MANAGER Is responsible for providing field engineering support to the OSWDF. Key project responsibilities include the following: Evaluates Request for Information (RFI) for compliance with approved design documents. 4

10 Provides value engineering during construction. Coordinates field engineering personnel assignments. Responsible for management of project files and records in accordance with procedures. Responsible for preparation and submittal of construction certification documentation to DOE for regulatory approval. Reviews/approves construction materials (aggregate, liner materials, pipe, etc.) to verify that they meet plans and specifications. Engineering Change Requests (ECR) initiation and processing. Ensures OSWDF field engineers are adequately trained and qualified OSWDF OPERATIONS MANAGER Has overall responsibility for OSWDF operation of the OSWDF. Key project responsibilities include: Ensures compliant operations of waste disposal (placement) in the OSWDF Ensures compliant operations of routine monitoring and maintenance of the OSWDF Ensures all work is performed safely activities are planned and performed in compliance with ISMS principles and core functions. Provides leadership and motivation to the project and organizational team as well as subcontractors and subordinate personnel. Follows Conduct of Operations, prime contract terms, company policies and procedures OSWDF PROJECT QA MANAGER Has overall responsibility for Quality Assurance/Quality Control (QA/QC) activities during construction and operations of the OSWDF. Key project responsibilities include: Manages the Construction Quality Control (CQC) contractor and Fluor-BWXT Portsmouth LLC QA/QC resources required to support the OSWDF project. Prepares and maintains OSWDF Project Quality Assurance Plan (PQAP). Develops annual OSWDF Project Surveillance and Assessment Schedule. Facilitates the performance of OSWDF QA surveillances during construction and operation of the OSWDF. Interfaces with DOE and other external entities as necessary on OSWDF QA issues and interpretations Assist with the development of corrective actions and the performance of follow-up to verify effectiveness of completed corrective actions. Reviews OSWDF project related documents for incorporation of QA requirements. Coordination of OSWDF supplier audits and assessments. 5

11 1.2.8 CQC CONTRACTOR FBP-ER-PL Under the direction of a Construction QA Officer, is responsible for conformance testing, monitoring, and performance testing in accordance with the OSWDF Construction Quality Assurance Project Plan (CQAPP) QA requirements. The CQC contractor will provide QC oversight during the placement of impacted materials in the cell during the operational phase of the OSWDF. Key project responsibilities for the CQA Officer and CQC contractor include: Obtaining and testing construction materials. Collecting soils samples for testing. Shipping samples to off-site laboratory for testing. Quality Control of off-site and on-site testing laboratory. CQA Officer prepares, signs, and seals yearly OSWDF CQA Construction Certification Report. Provides oversight of CQC activities during construction ensuring the CQA has been successfully carried out and the OSWDF has been constructed to the design documents. Certifies at project completion that the OSWDF has been constructed in accordance with the design documents OSWDF ES&H FIELD REPRESENTATIVE(s): Is responsible for the safe performance of work during the construction and operation of the OSWDF. Key responsibilities include: Ensures implementation of regulatory ES&H/Radiological requirements applicable to the project. Ensures ES&H and Radiological personnel matrixed to the project are trained and qualified to perform their duties. Observes work activities during construction and operations for unsafe/noncompliant practices. Interfaces with the U.S. Department of Energy and other external entities as necessary on ES&H/Radiological issues. Evaluates future work activities from an ES&H and Radiological perspective to ensure processes, documentation, training, and certifications needed are implemented. Ensures ES&H and Radiological permits are complete, properly executed and adhered to. Assists with development and review of Project Health and Safety Plans, Job Hazard Analysis, Radiological Work Permits, as low as reasonably achievable reviews, and associated hazard mitigation controls. 6

12 INTERIM LEACHATE TREATMENT SYSTEM CONSTRUCTION AND OPERATIONS QUALITY. Will be included in future revisions to the PQAP as the project enters the ILTS construction phase DESIGN ARCHITECT-ENGINEER (A-E) Responsible for the design of the OSWDF and the ILTS in accordance with contractual requirements and may include Title III engineering services CONSTRUCTION CONTRACTOR(s) Responsible for the construction of the OSWDF, ILTS, and placement of impacted materials in the OSWDF in accordance with contractual requirements and Certified for Construction design documents. 1.3 PROJECT QA RESPONSIBILITIES It is the OSWDF Project Director s responsibility to establish policy and cultivate principles that integrate quality requirements into daily work. It is also the OSWDF Project Director s responsibility to ensure implementation and adequate resources are allocated to implement the QA requirements in this PQAP It is the responsibility of all OSWDF project personnel to safely comply with the requirements of this PQAP and its implementing documents, to ensure conformance to approved design drawings and technical specifications, and to identify and report nonconforming items or problematic issues OSWDF personnel assigned the responsibility for verifying that activities affecting quality have been performed correctly, shall be independent of the work performed, have direct access to all levels of management, have access to all work areas, have independence from cost and schedule, and have sufficient authority to: Identify quality problems Recommend solutions to quality problems Verify implementation of solutions Ensure that further processing, delivery, installation, or use is controlled until proper disposition of a nonconformance, deficiency, or unsatisfactory condition has occurred. 7

13 OSWDF Project Director Deputy Director OSWDF Design Engineering OSWDF Field Engineering OSWDF Construction OSWDF Operations OSWDF CD Process OSWDF ES&H OSWDF QA OSWDF CAP-1 Project OSWDF CAP-2 Project Waste Placement CQC Contractor OSWDF QA/QC CQC Field Technicians CQA Officer CQC On/Offsite Laboratory Figure 1.1 OSWDF Project Organization Chart 1.4 STOP WORK AUTHORITY FBP stop work authority extends to all FBP personnel and subcontractors to prevent any work, activity, or process that jeopardizes personnel safety and health, quality, or has the potential to cause significant environmental impact This stop work authority is applicable to OSWDF project personnel and OSWDF subcontractor and is one of the mechanisms used to ensure that planning and scheduling considerations do not degrade safety, quality, or environmental performance Prior to restart of OSWDF related work after a work stoppage due to safety, quality or environmental concerns, appropriate reviews, critiques, and/or assessments are planned, performed, and documented. Conditions warranting the work stoppage are understood and resolved and remedial/corrective/preventative actions are completed. 8

14 1.4.4 The stop work authority requirement shall flow down to OSWDF sub-contractors through procurement documents, such as the Statement of Work, and Attachment J-13 Environmental, Health, and Safety Requirements for On-Site Work, documents, and reinforced through project team meetings, construction meetings, and during pre-job briefs. 1.5 MANAGEMENT PROCESSES The successful execution of the OSWDF project requires careful planning, scheduling, and allocation of qualified and trained resources necessary to ensure the OSWDF is designed, constructed, and operated in accordance with applicable ARARs Management processes to ensure successful project execution have been established and are defined in this PQAP which include training and qualification of personnel, quality improvement, records management, work processes, and project management guidelines that prescribe best management practices to effectively plan, execute, monitor, report, and close projects Management controls, lines of communication, and responsibilities are established in plans, procedures, and procurement documents to ensure adequate oversight of subcontracted work. 1.6 GRADED APPROACH FBP site procedure FBP-QA-PRO-00008, Graded Approach, was developed to implement the requirements of 10 Code of Federal Regulations (CFR) 830.7, Graded Approach. Quality Levels (QLs) 1-4 were developed to aid in the implementation of quality requirements by application of the graded approach to structures, systems, and components (SSCs), work activities, and subcontracted services affecting quality, with QL-1 having the highest consequence and risk down to QL-4 having the lowest consequence and risk Factors to be considered in determining appropriate levels of control required to verify compliance with QA requirements include: The hazards associated with doing the work or using the results of the work. The consequences of malfunction or failure of the item or inappropriate use of the results of services provided. The probability of the occurrence of the postulated consequences 9

15 The design and fabrication complexity or uniqueness of the item, or difficulty to perform services. The need for special controls and oversight of processes, equipment, and performance. The degree to which functional compliance can be demonstrated by inspection, test, or performance verification. The quality history and degree of standardization of items and services. The difficulty of repair, replacement, or replication The OSWDF project will utilize the graded approach during the design, construction, and operation of the OSWDF in accordance with the requirements prescribed in FBP-QA-PRO-00008, Graded Approach. 2.0 PERSONNEL TRAINING AND QUALIFICATION The FBP Training Program consists of classroom, computer-based training, laboratory training, and on-the-job training necessary to provide an understanding of the fundamentals, basic principles, systems, procedures, and emergency responses involved in an employee s work assignments. This enables efficient appropriate indoctrination, training, qualification, and where applicable, certification of personnel performing or managing activities affecting quality. FBP s training program is tailored to ensure employees and subcontractors are trained, qualified, and certified (when required) commensurate with the scope, complexity, importance of their work activities and job assignments. 2.1 QUALIFICATION AND TRAINING OF PERSONNEL The OSWDF Project manager during the initial scoping and planning phase of the project determines the required number of personnel and their qualification and experience needed to successfully execute the project. The program support organization(s) provide qualified and trained personnel to support the project execution team. The program support organizations are responsible to ensure personnel matrixed to the project are current with their required training in order to maintain job proficiency Project Contract Technical Representatives (CTRs) flow-down the project personnel qualification and experience requirements to subcontractors through procurement documents including, but not limited, to Statement of Work, J-13 Appendix 1, Training Matrix, Project Work Plan, and Health and Safety Plans. The CTR provides oversight verifying subcontractors complete required training prior to commencement of project work activities and complete continual training required to maintain job proficiency. 10

16 2.1.3 Personnel who perform testing activities that are not QC shall achieve and maintain proficiency in the performance of quality-affecting activities. Specific activities that require special qualifications or certifications include construction riggers, crane operators, welders, and laboratory analysts. Qualification, training, and job proficiency for construction personnel shall be the responsibility of OSWDF Construction Management. 2.2 QUALIFICATION OF INSPECTION AND TEST PERSONNEL OSWDF project QC personnel who perform inspections and tests for the purpose of verifying that material, equipment, components, or processes meet the specified requirements shall be qualified and certified to ASME NQA (Addenda through 2009), or an approved equivalent The FBP QA program support organization has the responsibility for ensuring FBP QC personnel supporting the project are qualified and certified in accordance with site procedures and the following requirements: Initial capabilities of a candidate shall be determined by an evaluation of the candidate s education, experience, training, and either test results or capability demonstration. The job performance of inspection and test personnel shall be reevaluated at periodic intervals not to exceed three years. Reevaluation shall be by evidence of continued satisfactory performance or redetermination of initial capability and satisfactory indoctrination and training requirements. If during this evaluation or at any other time, it is determined by the FBP QA program support organization that the capabilities of an individual are not in accordance with the qualification requirements specified for the job, that person shall be removed from the activity until such time as the required capability has been demonstrated. Any person who has not performed inspection or testing for a period of one year shall be reevaluated Subcontracted inspection and test personnel shall meet the same requirements as FBP personnel. The flow-down of FBP QC qualification and certification requirements shall be include in procurement documents QC non-destructive examination (NDE) personnel shall be qualified and certified in accordance with site QC procedures and the American Society of Nondestructive Testing (ASNT) ASNT- TC-1A. 11

17 3.0 QUALITY IMPROVEMENT FBP-ER-PL QUALITY IMPROVEMENT PROCESS FBP procedure FBP-QP-PRO-00020, Problem Reporting and Issues Management. will be used to detect and prevent quality problems during the design, construction. and operation of the OSWDF. Items, materials, services, and processes that do not meet established requirements will be promptly identified, documented on a problem report, controlled (segregated where practical), corrected; and measures taken to minimize the reoccurrence of the identified nonconforming condition OSWDF problem reports will be are screened and categorized according to their significance, e.g., deficiency or significant deficiency. Based on the results of the screening, OSWDF problem reports may require casual analysis, extent of condition; but all problem reports will require corrective actions to correct the nonconforming condition OSWDF problem reports will be tracked through closure using the FBP Integrated Tracking System (ITS). The ITS is used to screen, categorize, document assignment of corrective and preventative actions, and to track the status of problem reports through closure Methods that may be used on the OSWDF project to identify quality issues include, but not limited to, inspections, surveillances, testing, document reviews, walk-downs, and independent and management assessments OSWDF subcontractors shall use the FBP problem reporting and issues management process to identify, control and correct non-conforming conditions, or use their own quality improvement program approved by the FBP OSWDF Project OSWDF subcontractors shall flow-down the quality improvement requirements of this section to their subcontractors, vendors, and suppliers. 3.2 NONCONFORMING ITEMS FBP-QA-PRO-00128, Control of Nonconforming Items. shall be used to document OSWDF nonconforming conditions on a nonconformance report (NCR) when an item or material: Fails to satisfy technical or contract requirements. Fails to comply with predetermined engineering specifications. Fails to function as specified. Appears to be suspect or counterfeit item (SC/I). Documentation deficiencies. 12

18 Lacks required testing or qualification with a nationally recognized testing laboratory unless evaluated and accepted by the FBP authority having jurisdiction A tagging or segregation system consistent with the requirements of FBP-QA-PRO-00128, Control of Nonconforming Items. shall be used for indeterminate or nonconforming items or materials to ensure those items or materials are not used until the disposition has been approved and documented on the NCR. 3.3 CONTINUOUS FEEDBACK AND IMPROVEMENT Several methods are available to OSWDF project team members to participate in the continuous feedback and improvement process, (ISMS Principle 5) during the life cycle of the OSWDF project including project meetings, hazard identification, pre-and post-job briefings. OSWDF project involvement in the continuous feedback and improvement process is encouraged. 4.0 DOCUMENTS AND RECORDS 4.1 DOCUMENTS Approved FBP work documents including plans, procedures, policies, design drawings, and specifications are employed by the OSWDF project team to manage and control work during the design, construction, and operation of the OSWDF. OSWDF subcontractors are procured to assist in the design, fabrication, and construction of the OSWDF using approved design documents, FBP work documents, or subcontractor documents approved by FBP Work documents establish requirements and define how work is to be performed. They shall be prepared, reviewed, approved, issued, used, and revised in a controlled manner in accordance with approved procedures Specific controls to be applied to work documents include: Identification of controlled work documents. Establishing controlled work document distribution list. Identification of individuals responsible for the preparation, review, approval, and distribution of controlled work documents. Reviewing and approving of controlled work documents prior to distribution. Establishing processes to ensure correct revision of controlled work documents are being used. 13

19 Identifying minor revisions to controlled work documents. FBP-ER-PL Identifying field changes in accordance with FBP-BS-PRO OSWDF work documents (FBP or subcontractor) shall be controlled and have the latest approved version in hand at the time of use. It is the responsibility of the person performing the work to ensure that the latest version of the work document is available at the work area Revisions to work documents shall be reviewed and approved by the same organization that reviewed and approved the original document, unless it is a minor revision, as defined in FBP-BS-PRO-00024, Developing and Maintaining Technical Procedures. 4.2 RECORDS Records furnish documentary evidence that that items or activities meet specified requirements. The term records as used throughout this section are considered QA Records. Records are classified as either lifetime or nonpermanent which will be further defined Records generated as a result of the design, construction, maintenance, and operation of the OSWDF shall meet the record generation, authentication, classification, receipt, storage, maintenance, and retention requirements prescribed in FBP-BS-PRO-00062, Records Management Process, which include the following: Shall be accurate, legible, reproducible, retrievable, authenticated, and complete. As a best management practice, lines and spaces which are not applicable to the activity or task conducted should contain an N/A. If logs or sheets have multiple unused lines remaining, a single diagonal line should be drawn through the blank lines, with the words no further entries along with an initial and date of the recorder. Record generator shall be responsible to ensure records are validated and/or authenticated by appropriate personnel. Records that create or reiterate design data, technical data, or process controls, as a minimum, shall contain signatures of the preparer and of an independent reviewer, checker, and approver. Electronic documents are authenticated similarly to paper records with authorization indicated on the media or contained within or linked to the document itself. Record custodians are responsible for facilitating the receipt and inspection of authenticated records and maintaining the compliant field (temporary) storage until transmittal to RMDC. 14

20 Access controls are established to prevent unauthorized use, disclosure, theft, or destruction of records. Lists are posted designating personnel approved for access to the records Temporary storage of QA records (such as for processing, review, and use) is required, the single storage facility or container shall provide a one hour fire rating, unless dual storage requirements are met FBP records management requirements shall flow down to OSWDF subcontractors through the procurement process. Subcontractor quality assurance plans (QAPs), if required, shall include FBP record management requirements. Subcontractor QAPs shall be submitted to FBP for review and approval. 5.0 WORK PROCESSES 5.1 INSTRUCTIONS, PROCEDURES, AND DRAWINGS The work associated with the design, construction, and operation of the OSWDF will be a combination of self-performed and subcontracted, but in both cases the work will be performed in accordance with approved instructions, procedures, drawings, specifications, or other approved documents A graded approach, as previously discussed, and prescribed in FBP-QA-PRO-00008, Graded Approach is used in the development of work control documents and implementation of QA requirements ensuring that the level of analysis, documentation, and actions used to comply are commensurate with: Relative importance of safety, safeguards, and security Magnitude of any hazard involved Life-cycle stage of a facility or item Programmatic mission of a facility Relative importance to radiological and non-radiological hazards Other relevant factors Documents used to define and perform work must comply with the requirements of applicable technical standards, vendor manuals, safety basis documents, codes, specifications, drawings, 15

21 subcontract terms and conditions, and other applicable technical documents. These documents are developed using technical, health, safety, environmental, and quality requirements; and reviewed by qualified and knowledgeable personnel to ensure applicable and appropriate requirements are incorporated into the documents OSWDF work performed by subcontractors are required to work to the requirements of this PQAP, or to a QAP developed to include these requirements by the subcontractor, and approved by OSWDF project personnel. Programmatic requirements imposed on the subcontractor are defined by the terms and conditions of the subcontract; including the requirement to work to FBP work control documents, or to develop the necessary documents, plans, or procedures to perform their work scope. 5.2 IDENTIFICATION AND CONTROL OF ITEMS Procedures shall be used to assure that only correct and accepted items are used during the construction and operation of the OSWDF. Items include materials, equipment, components, appurtenances, assemblies, modules, parts, structures, subsystem units, subassemblies, and systems Physical identification shall be used to the maximum extent possible. Where physical identification on the item is either impractical or insufficient; physical separation, procedural control, or other appropriate means shall be employed Item identification shall be maintained on the item or in documentation traceable to the item from initial receipt or fabrication up to and including installation or use. When items are subdivided, identification shall be transferred to each part of the item prior to subdivision, and the identification shall not be obliterated or hidden by subsequent surface treatment or coating unless other means of identification are employed Provisions shall be made to ensure traceability of items are not lost due to degradation or weathering. Items having a limited shelf life or operating life shall be managed to ensure inadvertent use after expiration. 16

22 5.3 CONTROL OF SPECIAL PROCESSES FBP-ER-PL Special processes that control or verify quality, such as welding, heat treating, brazing, soldering, and NDE, shall be performed by qualified personnel in accordance with approved and controlled procedures developed from applicable codes, standards, specifications, and other requirements Special processes shall be controlled by instructions, procedures, drawings, checklists, or other appropriate means; and shall include or reference procedure, personnel, and equipment qualifications requirements. Conditions necessary for accomplishment of the process shall include proper equipment, controlled parameters of the process, specified environment, and calibration requirements In addition to special processes previously listed, unique to the OSWDF project will be fusion and extrusion welding of the geomembrane liner and cap seams. The subcontractor shall submit procedures that will be used to control the fusion and extrusion welding of the geomembrane liner and cap seams to FBP for review and approval prior to commencement of the work activity For special processes not covered by existing codes and standards, requirements for qualification of personnel, procedures, or equipment shall be specified or referenced in procedures or instructions and submitted to FBP for approval Acceptance criteria for each special process shall be specified or referenced in procedures or instructions. Records shall be maintained for qualified personnel, processes, and equipment for each special process. 5.4 CONTROL OF MEASURING AND TEST EQUIPMENT Tools gauges, instruments, and other measuring devices used during the construction and operation of the OSWDF by FBP personnel or subcontractors shall be controlled, calibrated, and maintained to required accuracy limits. Procedures shall be developed to ensure Materials and Test Equipment (M&TE) is of the proper type, range, accuracy, and calibration frequency 17

23 needed to accomplish the required measurements for determining conformance to specified requirements Calibration shall be against and traceable to certified equipment or reference standards having known valid relationships to nationally recognized standards. Where no standards exist, the basis for calibration shall be defined. Reference standards shall have a minimum four times greater than that of the M&TE being calibrated. Where the 4:1 ratio cannot be maintained the basis for selection of the standard shall be technically justified When M&TE is lost, damaged, or found to be out of calibration; the validity of previous measurements, inspection, or test results shall be re-evaluated for acceptability from at least the last acceptable calibration of the suspect M&TE M&TE shall be: Traceable to its application and use. Marked or labeled to indicate calibration status and traceability to calibration records. Properly handled and stored to maintain accuracy, including environmental controls. Submitted for calibration shall be checked and results recorded before any adjustments or repairs are made Records shall be maintained to indicate calibration status. Calibration reports and certificates shall include the information and data necessary for interpretation of the calibration results and verification of conformance to applicable requirements. 5.5 HANDLING, STORAGE, AND SHIPPING The requirements for handling, storing, shipping, cleaning, and preservation of items that will be used on the OSWDF project shall be defined in FBP procedures for self-performed work and in subcontractor work documents and procedures for subcontracted work Included in the work documents and procedures shall be instructions for marking and labeling items for packaging, shipping, handling, and storing to adequately identify, maintain, and 18

24 preserve the items integrity, including indication of the presence of special environments, controls, and safe handling requirements. 5.6 INSPECTION, TEST, AND OPERATING STATUS Indicators shall be used by OSWF Project and subcontract personnel to identify the status of inspections and tests to ensure that required inspections and tests are performed and that items that have not passed the required inspections and tests are not inadvertently installed, used, or operated. Status shall be maintained through indicators such as physical locations and tags, markings, inspection records, work travelers, stamps, or other suitable means. The process for using status indicators shall be proceduralized and include responsibilities and authority for removal Procedures shall also include a method for indicating the operating status of systems and components of a facility, such as the Interim Leachate Treatment System (ILTS), by tagging valves and switches to prevent inadvertent operation. 6.0 DESIGN CONTROL 6.1 BASIC Controls are established to ensure that items and processes are designed using sound engineering and scientific principles and the selection of appropriate standards using the graded approach. Procedures are developed that define the design process from initial conception through final design approval. Design changes shall be governed by control measures commensurate with those applied to the original design Design may be self-performed by OSWDF or performed by organizations external to FBP commonly referred to as architect-engineer (A-E) firms. Regardless of who develops the design, the FBP Engineering Manager is the design authority and ultimately responsible for approving all designs developed for the OSWDF project When a design is to be developed by an A-E or another organization external to FBP, the requirements with the appropriate level of rigor shall be contractually flowed down to the subcontractor through the subcontract language. 19

25 6.1.4 The OSWDF project will use FBP approved design control procedures, or if the design is subcontracted to an A-E firm, the A-E firm will submit their design control procedures to FBP for approval prior to commencement of the design The following design process sections are standard requirements from FBP-QA-PDD-00001, Quality Assurance Program Description (QAPD) and shall apply to OSWDF self-performed design; or if the design is subcontracted, the FBP design requirements shall flow down to the subcontractor(s) performing design activities. 6.2 DESIGN INPUT Design inputs are identified and documented; and their selection reviewed and approved. The design input shall be specified to the level of detail necessary to permit the design activities to be carried out in a correct manner and to provide a consistent basis for making design decisions, accomplishing design verification measures, and evaluating design changes Requirements for determining the design basis may include: Basic function and performance requirements Safety basis requirements Environmental conditions Material requirements Safety, quality, and fire protection requirements. Reliability requirements. Applicable code, standards, and other quality requirements. 6.3 DESIGN PROCESS The responsible design organization prescribes and documents the design activities in specifications, calculations, drawings, test plans, etc., in accordance with approved procedures, to the level of detail necessary to permit the design process to be carried out in a correct manner and to permit verification that the design meets all requirements. Design documents support OSWDF design, construction, and operation. 20

26 6.3.2 The design methods, materials, parts, equipment, and processes that are essential to the function of the items are selected and reviewed for suitability of application. Applicable information derived from experience, as set forth in reports or other documentation, is made available to applicable design personnel OSWDF engineering ensures that each final design: Is traceable to the design input by documentation in sufficient detail to permit design verification. Specifies required inspections and tests and includes and references appropriate acceptance criteria. Identifies assemblies and/or components that are a part of the item being designed. When such assembly or component part is a commercial grade item (CGI), the critical characteristics of the item to be verified for acceptance and the acceptance criteria for those characteristics shall be documented. Ensures Commercial grade dedication (CGD) shall be performed in accordance with approved FBP procedures, or procedures approved by FBP if CGD is performed by a subcontractor The design control processes correctly translate appropriate codes, standards, and quality requirements to ensure SSC s meet their specified design requirements, and their selection reviewed and approved. The modification team is required to ensure a multi-discipline review is performed which identifies interface requirements, design input requirements, to perform design input/output reconciliation, and to approve design implementation requirements. The design control process is performed in accordance with approved FBP design control procedures, or procedures approved by FBP procedures if performed by a subcontractor. 6.4 DESIGN ANALYSIS The design analysis process shall be sufficiently detailed in drawings, specifications, calculation, etc., that such a person technically qualified in the subject can review and understand the analyses, and verify the adequacy of the results without recourse to the originator. 6.5 DESIGN VERIFICATION The OSWDF project identifies and documents the particular design verification method(s) to be used. The methods shall be compliant with FBP site design control procedures. 21

27 6.5.2 Results of the design shall be documented with the identification of the verifier s clearly indicated. Design verification is performed by any competent individual(s) other than those who performed the original design, but who may be from the same organization. The verification may be performed by the originator s supervisor, provided the supervisor did not specify a singular design approach or rule out certain design considerations and did not establish the design inputs used in the design; or the supervisor is the only individual in the organization competent to perform the verification. 6.6 CHANGE CONTROL Configuration management (CM) (FBP-NSE-PDD-00002, Configuration Management Program Description) is applicable to the OSWDF project. CM procedure implementation of operating facilities, e.g., OSWDF and the ILTS, shall be established and documented at the earliest practical time prior to operation and CM shall be maintained for the life of the facility. CM procedures shall include the responsibilities and authorities of the organizations whose function affect the configuration of the OSWDF and ILTS including activities such as operators, designs, maintenance, construction, licensing, and procurements. The design change process per FBP-NSE-PRO-00081, Design Control, applies to all facility changes The configuration of a facility shall be documented in drawings, specifications, procedures, and other documents that reflect the operation of the facility. The configuration includes, as applicable, characteristics derived from regulatory requirements and commitments, calculations and analyses, design inputs, installation and test requirements, supplier manuals and instructions, operating and maintenance agreements, and other applicable sources. 6.7 INTERFACE CONTROL Design interfaces shall be identified/established during the design phase and controlled using subcontract language, procedures, instructions, and/or formal agreements to provide effective coordination of design effort among and within participating organizations. This interface control is provided by the CM Program FBP-NSE-PDD-00002, Configuration Management Program Description, and the design change procedure FBP-NSE-PRO These controls include a description of the responsibilities of the affected organizations for initiation, development review, approval, release, distribution, revision of design documents, and management of the overall design tasks. 6.8 CONTROL OF ENGINEERING SOFTWARE Refer to Section 11, of this document, Software QA, for the development, verification, validation, and use of engineering software in support of the OSWDF project. 22